However, each time a new physical or health hazard is identified, your employees need training—that’s the mandate for employers.

Also, I checked and California’s standard (§5194. Hazard Communication) was revised last year simply to amend the definition of “Safety Data Sheets”, so no training required.

Here are some best practices for employers…

Employers should review the new SDSs in a timely fashion upon receipt.

If the employer does not receive the SDSs in a timely fashion, it should promptly communicate in writing with the manufacturer to obtain the SDSs. If the employer does not receive the SDSs by June 1, 2016, OSHA has indicated that it will not cite employers who show “good faith efforts” to obtain the SDSs.

Employers should continuously evaluate the workplace using the SDSs to identify hazardous chemicals and how their employees may be exposed.

Employers whose employees work with or around hazardous chemicals must ensure that they review the updated SDSs and assess each of the employer’s underlying compliance programs (e.g., emergency action plan, storage of flammable and combustible materials, PPE, respiratory protection, etc.) that may be impacted by the SDSs.

Employers should ensure that employees who work with or around hazardous chemicals are trained to recognize the pictograms and hazard warnings that will be required under the new Hazard Communication Standard. Employers should document this training and develop mechanisms to ensure that employees understand the hazards of working with or around hazardous chemicals.

If you’re interested, check out a preview of our online training for HAZCOM (GHS) – it’s one of our top 10.